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Constitutional Law Keyed to Choper
Smith v. Allwright
Citation:
321 U.S. 649 (1944)Facts
In 1940, Lonnie Smith, an African American citizen residing in Harris County, Texas, attempted to vote in the Democratic Party primary election. The Democratic Party in Texas had adopted a resolution in 1932 restricting party membership to white citizens only. Election officials, including defendant Allwright, refused to allow Smith to vote solely because of his race. At this time in Texas, the Democratic Party’s primaries were effectively the only meaningful elections due to the party’s dominance in the state. Texas law extensively regulated the primary election process, including requiring primaries for parties that received over 100,000 votes in the previous general election, setting dates for primaries, establishing qualifications for voters, and providing for state courts to have jurisdiction over election contests. The state had previously attempted various methods to exclude Black voters from Democratic primaries, which had been struck down in earlier Supreme Court cases (Nixon v. Herndon and Nixon v. Condon).
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